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If the regulations apply,
the facility must provide the quantities and locations of the substances to
Environment Canada. The regulations also require the preparation and
implementation of environmental emergency plans detailing prevention,
preparedness, response, and recovery measures in case of an environmental
emergency. Under the regulations, Environment Canada must be notified regarding
the presence of regulated substances and the development and implementation of
an Environmental Emergency Plan.
Who Is Impacted By The
Regulation?
Any commercial or
industrial facilities that stores or uses any of the substances targeted by the
regulation, and that meet specified minimum quantities must comply with the
requirements of the regulation. The regulation initially targets 174 substances,
including flammable and other hazardous materials. The regulations apply to both
pure substances and mixtures. Application to mixtures containing listed
flammable substances is determined by flash and boiling points of the mixture.
The applications do not apply to substances in containers that have a maximum
capacity of 30 kg or less. The list of substances may be viewed at
http://cepae2.ec.gc.ca.
Environmental Emergency
Plan Requirements
The
E2 Plan must be site specific and consider both the facility’s operations and
surroundings. The properties and characteristics of the substances and the
maximum quantities expected on site must also be considered during preparation.
It must also address the potential consequences to the environment and human
life and health. Plan requirements are summarized as follows:
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A
description of the factors considered in the development of the plan,
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Identification
and assessment of any potential environmental emergencies that can
reasonably be expected to occur at the facility and that would likely cause
harm to the environment or present a danger to human life,
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Measures
to be used to prevent, prepare for, respond to and recover from the
potential environmental emergencies identified above,
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A
list of individuals responsible for executing the plan, including a
description of their roles and responsibilities,
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Training
required for each of the above individuals,
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A
listing of emergency response equipment and its location.
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Measures
to be taken to notify members of the public who may be adversely affected by
an environmental emergency
What
Do I Have To Do?
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Determine
if your operations store or use any of the 174 substances initially targeted
and that meet or exceed the specified minimum quantities.
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Prepare
and submit to Environment Canada a Notice of identification of substance
and place within 90 days of the regulations coming into force, or 90 days after a substance reaches or exceeds the prescribed
quantity. The notice must identify:
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the
facilities to which the regulations are applicable,
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the
location of the facility,
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the applicable substance or substances,
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the
maximum amounts used or stored at anytime during a year.
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Prepare
an Environmental Emergency Plan in accordance with the regulations. An
existing emergency plan can be used, modified as necessary to meet the
requirements of the regulation.
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Notify
Environment Canada that the required E2 plan has been prepared (Notice of
preparation). This notice is to be submitted within six months of the
regulations coming into force, or six months after a
substance reaches or exceeds the prescribed quantity.
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Implement
and test the E2 plan. An environmental emergency plan can be considered
implemented when it is operational to the point where the person submitting
the notice can expect to successfully deal with all aspects of an
environmental emergency. Implementation includes prevention, preparedness,
response and recovery documentation, access to the identified response
resources, training, and testing sufficient to validate the plan. It should
include provision for annual testing and review of the E2 plan, including
keeping records of the test results.
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Submit
to Environment Canada a Notice of implementation and testing
signifying that the E2 plan has been implemented and tested. The notice is
to be submitted within a year of the regulations coming into force, or a year after a substance reaches or exceeds the prescribed
quantity.
Annual
Updating and Testing
The
environmental emergency plan must be updated and tested at least once a year to
ensure that the plan continues to meet the regulatory requirements. A record of
the updates and test results must be kept with the plan for at least 5 years.
Record
Retention and Reporting
In
addition to the Environment Canada notices discussed above, documentation and
reporting requirements under the regulation include:
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Copies
of the E2 Plan must be available to all persons responsible for
implementation.
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A
record of annual updates and the results of annual tests must be retained
with the plan for at least 5 years.
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The
regional office of Environment Canada must be provided both verbal and
written notification of all emergencies involving substances controlled
under the regulation.
ALTECH
Capabilities
Altech
Environmental Consulting Ltd. can assist with all aspects of the E2 Regulations.
Our capabilities with regards to environmental emergency plans include:
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Assessment
of risks associated with the storage and handling of hazardous substances,
including their potential impact on the environment and human health, both
on- and off-site. Risk assessments performed by Altech also evaluate the
impact of potential interaction between hazardous substances.
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Development
of an environmental emergency plan to address the potential risks to the
environment and human health identified by the risk assessment, and comply
with the requirements of the E2 Regulations.
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Development
and implementation of training programs specific to the environmental
emergency plan
For
more information on how Altech can assist please contact Henri van Rensburg by
email
or phone at 1-800-323-4937 Ext. 230.
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